This episode brings together our CCI and contentious regulatory teams to consider the impact of the Failure to Prevent Fraud offence on financial institutions. Jon Ford, Elizabeth Head and Ally Fitzgerald explore the risk areas that financial institutions may be exposed to as well as why financial institutions may be at an increased risk of enforcement in comparison to other organisations. They also provide insight into the steps that the HSF Kramer team have seen financial institutions take to prepare themselves for the September implementation date.

Please also see our blogpost https://www.hsfkramer.com/notes/fsrandcorpcrime/2025-posts/ftpf-financialinstitutions for further discussion of this topic, and this briefing https://www.hsfkramer.com/notes/fsrandcorpcrime/2025-posts/ftpfraud-ready-sep25 for an overview of the new offence of Failure to Prevent Fraud.